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2024 (8) TMI 569

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..... e, this appeal u/s 260A cannot be filed by the Revenue - order passed by the Tribunal quashing an order u/s 263 of the Act was not appealable - HELD THAT:- Upon a careful perusal of the relevant clauses of the aforesaid circular, it appears that where the tax liability is not quantifiable or is not involved, in such cases the order passed u/s 263 of the Act would fall under the exception provided .....

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..... Act, 1961 (hereinafter referred to as 'the Act') arising out of judgment and order dated December 21, 2023 passed by the Income Tax Appellate Tribunal, Delhi Bench 'H', New Delhi (hereinafter referred to as 'the Tribunal') for the assessment year 2017-2018 whereby the Tribunal has quashed the order passed by the Principal Commissioner of Income Tax, Noida. 3. Upon a perusa .....

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..... on behalf of the Income Tax Department submits that the present appeal falls under the exception provided in Clause 3.1(f) of the aforesaid circular. The relevant portion of the aforesaid circular is delineated below for ready reference:- 3.1 Monetary limits given in paragraph 4 with regard to filing appeal/SLP shall be applicable to all cases including those relating to TDS/TCS under the Act with .....

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..... ection 260A of the Act. 7. We have considered the arguments placed on behalf of counsel appearing on behalf of the parties. 8. Upon a careful perusal of the relevant clauses of the aforesaid circular, it appears that where the tax liability is not quantifiable or is not involved, in such cases the order passed under Section 263 of the Act would fall under the exception provided in Clause 3.1(f). I .....

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